State Of Washington, V. James W. Anderson

CourtCourt of Appeals of Washington
DecidedJanuary 21, 2026
Docket59813-2
StatusPublished

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Bluebook
State Of Washington, V. James W. Anderson, (Wash. Ct. App. 2026).

Opinion

Filed Washington State Court of Appeals Division Two

January 21, 2026

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II STATE OF WASHINGTON, No. 59813-2-II

Respondent,

v.

JAMES WAYNE ANDERSON, PUBLISHED OPINION

Appellant.

CRUSER, C.J.—James Wayne Anderson appeals the trial court’s order amending his

sentence based on his new offender score. Anderson argues that the trial court should have vacated

his entire judgment and sentence and conducted a de novo resentencing, at which Anderson would

have the opportunity to allocute and present mitigating evidence. The State argues that Anderson

was not entitled to vacation of his judgment and sentence or to be resentenced, but that even if he

was, vacating the judgment and sentence would not affect the underlying factual findings in

support of his exceptional sentence. The State concedes, however, that if Anderson was entitled to

a full resentencing hearing, he did not receive one and that a resentencing hearing would be

required during which Anderson can allocute and present mitigating evidence and argument. The

State argues that if resentencing is required, the resentencing court is permitted to rely on the

original factual findings in support of an exceptional sentence if it determines, in its discretion,

that an exceptional sentence above the standard range is warranted. No. 59813-2-II

We hold that the trial court vacated Anderson’s judgment and sentence when it revisited

his sentence and exercised discretion in changing it. We also hold that the trial court erred when it

failed to conduct a proper resentencing hearing, and that on remand Anderson must be given the

opportunity to allocute and present mitigating evidence and argument in support of his sentencing

recommendation, including evidence about his youth at the time of the crime and any rehabilitation

efforts he has undertaken since his initial sentencing in this case. We further hold that Blakely v.

Washington, 542 U.S. 296, 124 S. Ct. 2531, 159 L. Ed. 2d 403 (2004) does not apply to Anderson’s

resentencing and the factual findings made by the original sentencing court in support of his

exceptional sentence are unaffected by the vacation of his judgment and sentence. On remand, the

superior court has full discretion to impose any sentence it believes is warranted, including a

standard range sentence, an exceptional sentence below the standard range, or an exceptional

sentence above the standard range so long as it is based on only the two aggravators that were

previously affirmed by this court on appeal.

FACTS

In 1999, James Anderson pleaded guilty to first degree murder, which he committed when

he was 19 years old. Anderson’s offender score was 3, and his standard sentencing range was 271-

361 months. The trial court made two factual findings that could support an exceptional sentence

above the standard range: that the victim was particularly vulnerable and that Anderson acted with

deliberate cruelty. In pronouncing Anderson’s sentence, the court determined that substantial and

compelling reasons supported an exceptional sentence above the standard range. The court

determined that an appropriate sentence would be double the midpoint of the standard sentencing

2 No. 59813-2-II

range. The court then sentenced Anderson to 632 months. It further indicated that it would have

sentenced Anderson to double the midrange, regardless of his offender score.

Anderson appealed his sentence, arguing that there was insufficient factual support for the

sentencing court’s finding that the victim was particularly vulnerable. Anderson did not challenge

the sentencing court’s finding that he acted with deliberate cruelty.1 We affirmed. Following the

United States Supreme Court’s decision in Blakely, 542 U.S. at 296, Anderson filed a personal

restraint petition (PRP) arguing that he was entitled to a jury determination of the aggravating

factors supporting his exceptional sentence, but we denied his PRP because Blakely is not

retroactive.

In 2024, Anderson filed a CrR 7.8 motion to vacate his judgment and sentence and for

resentencing pursuant to State v. Blake, 197 Wn.2d 170, 481 P.3d 521 (2021). At the trial court’s

first hearing on the motion, it scheduled a resentencing hearing. On the date of the scheduled

resentencing, however, the trial court did not resentence Anderson. Instead, it asked Anderson and

the State for briefs addressing whether Anderson was entitled to vacation of his entire judgment

and sentence, and if so, whether the court could impanel a jury pursuant to Blakely. The court

expressed that if it were to resentence Anderson, it would consider “information subsequent to Mr.

Anderson being incarcerated,” which includes information on young adults’ neurodevelopment

that Anderson had submitted to the court. Verbatim Rep. of Proc. (VRP) at 21. After another

hearing, at which the court heard oral arguments, it decided to adjust Anderson’s offender score

instead of vacating and resentencing. The trial court expressly stated it was not vacating

Anderson’s judgment and sentence.

1 State v. Anderson, noted at 101 Wn. App. 1078, 2000 WL 1156882, (2000).

3 No. 59813-2-II

The trial court adjusted Anderson’s offender score down to 2. Correspondingly, his

standard range was reduced to 261-347 months. The State asked the court to utilize the same

sentence formula it used before: double the midpoint of the standard range. The court imposed an

exceptional 608-month sentence, which is double the midpoint of Anderson’s new standard range

based on the prior sentencing court’s findings of deliberate cruelty and vulnerable victim.

Anderson did not allocute or present any mitigating evidence or argument. In its order, the court

stated that the judgment and sentence should be amended “due to a re-sentence based upon a

Vacated Felony Conviction pursuant to State v. Blake.” Clerk’s Papers at 49 (italics added).

ANALYSIS

In addressing Anderson’s motion to vacate his judgment and sentence and for resentencing,

the superior court stated that it did not intend to grant Anderson’s motion to vacate. Instead, the

superior court characterized its decision to revisit Anderson’s sentence as merely an “adjustment”

of the sentence. For the reasons we explain below, we hold that the superior court vacated

Anderson’s judgment and sentence when it amended his sentence and exercised its discretion in

setting forth a new incarceration term. We further conclude that the court erred at the resentencing

hearing when it failed to invite Anderson to allocute and present the mitigating evidence and

argument he wanted the court to consider. At Anderson’s resentencing, the trial court may rely on

the original sentencing court’s findings of vulnerable victim and deliberate cruelty, as Blakely is

inapplicable to Anderson’s resentencing.

4 No. 59813-2-II

I. VACATION OF THE JUDGMENT

We begin our analysis by recognizing the trial court’s observation about the decisions of

our supreme court and the court of appeals about whether, or to what degree, a judgment and

sentence is vacated when the superior court grants relief under Blake:

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Related

Blakely v. Washington
542 U.S. 296 (Supreme Court, 2004)
State v. Parker
937 P.2d 575 (Washington Supreme Court, 1997)
State v. Crider
899 P.2d 24 (Court of Appeals of Washington, 1995)
Matter of Johnson
933 P.2d 1019 (Washington Supreme Court, 1997)
State v. Rowland
272 P.3d 242 (Washington Supreme Court, 2012)
State v. Canfield
116 P.3d 391 (Washington Supreme Court, 2008)
State v. Toney
205 P.3d 944 (Court of Appeals of Washington, 2009)
State v. Kilgore
216 P.3d 393 (Washington Supreme Court, 2009)
State v. Rowland
249 P.3d 635 (Court of Appeals of Washington, 2011)
In re Pers. Restraint of Light-Roth
422 P.3d 444 (Washington Supreme Court, 2018)
State Of Washington v. Anthony Thomas Waller
458 P.3d 817 (Court of Appeals of Washington, 2020)
In re the Personal Restraint of Snively
320 P.3d 1107 (Washington Supreme Court, 2014)
In re the Personal Restraint of Johnson
131 Wash. 2d 558 (Washington Supreme Court, 1997)
State v. Parker
132 Wash. 2d 182 (Washington Supreme Court, 1997)
State v. Canfield
154 Wash. 2d 698 (Washington Supreme Court, 2005)
State v. Kilgore
167 Wash. 2d 28 (Washington Supreme Court, 2009)
In re the Personal Restraint of McWilliams
340 P.3d 223 (Washington Supreme Court, 2014)
State v. O'Dell
358 P.3d 359 (Washington Supreme Court, 2015)
State v. Toney
149 Wash. App. 787 (Court of Appeals of Washington, 2009)
State v. Rowland
249 P.3d 635 (Court of Appeals of Washington, 2011)

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